Motion For Enlargement of Time in Which to Answer Interrogatories

     [||4c5389db-e90c-41dc-af43-5d40a545c245||] — ' 

  

UNITED STATES DISTRICT COURT F | | F D 

FOR THE 

JUN 211977 
NORTHERN DISTRICT OF INDIANA = 19 

RRS Lp 1 
HAMMOND DIVISION J FRANCIS T. GRANDYS, CLERK 

U. S. DISTRICT COURT 
  

RICHARD GORDON HATCHER, et al., 

Plaintiff, 

VS. CIVIL ACTION NO. H77-154 

METHODIST HOSPITAL OF GARY, INC., 

an Indiana Not-for-Profit Corporation, 
et al., 

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Defendants 

MOTION FOR ENLARGEMENT OF TIME 

IN WHICH TO ANSWER INTERROGATORIES 
  

Come now the Defendants, Methodist Hospital of Gary, Inc. 

and Denis E. Ribordy, by counsel, and move the Court for an extension 

of time in which to answer or otherwise respond to Plaintiffs 

Interrogatories propounded to the Defendants, specifically reserving 

all Defendants' rights to object to any or all of the Interrogatories 

as propounded. Defendants ask the Court to grant them an enlarge- 

ment of time for a period of sixty (60) days to and including 

August 24, 1977, and in support thereof state as follows: 

(1). That Answers to the Interrogatories as propounded by the 

Plaintiff require extensive and time consuming research, investiga- 

tion, computation and compilation of copious materials which simply 

cannot be physically accomplished by the reasonable utilization 

of current administrative and legal personnel within the time limits 

established by the Plaintiffs; 

(2) That counsel for the Defendants has diligently researched 

and examined various aspects of the law with regard to these 

Interrogatories with the expectation of preparing a detailed 

 



  

in ion * 
response to the Plaintiffs' Interrogatories, but that because of 

the extensive and comprehensive nature of these inquiries has 

as yet been unable to complete such a response; 

(3) That the Defendants have been veguived to spend inordinate 

time in defending and responding to a similar lawsuit filed by 

many of the same groups who stand as Plaintiffs herein and the 

same attorneys who represent the Plaintiffs herein and in responding 

to various inquiries from the Gary Human Relations Commission, 

which lawsuit and inquiries have significantly strained the adminis- 

trative and legal resources available to the Defendants; and 

(4) That the Defendants believe that the requested extension 

of time will enable them to properly answer or otherwise respond 

to the Plaintiffs' Interrogatories and that such an extension will 

not prejudice the Plaintiffs' case. 

WHEREFORE, Defendants Methodist Hospital of Gary, Inc. and 

Denis E. Ribordy move the Court for an enlargement of time in 

which to answer or otherwise respond to the Plaintiffs' Interroga- 

tories to Defendants of sixty (60) days, to and including August 24, 

1977. 

Respectfully submitted, 

HODGES, DAVIS, GRUENBERG, COMPTON 

ik NS 

Saad Kis    id 

      

  

BY! 

ward J. Hussg&y 
5525 Broadway 7 
Gary, Indiana 46410 / 
Ph. (212) .981-2557 

 



  

fi 
UNITED STATES DISTRICT COURT Tl Rw CD 

FOR THE JU 0 
«11977 

NORTHERN DISTRICT OF INDIANA hr aR 

ANCIS T pa mmemssee : CIS [} GRANDYq Treas { 

HAMMOND DIVISION Us DISTRICT , CLEP 
. C Sr 1 

  

RICHARD GORDON HATCHER, 

WILLIE LEE PAGE, 

METRO CORPS OF GARY, INC., a 

Not-for-Profit Corporation, 

and others similarly situated, 

Plaintiffs, 

VS. CIVIL ACTION NO. H 77-154 

METHODIST HOSPITAL OF GARY, INC., 

an Indiana Not-for-Profit 
Corporation, and DENIS FE. RIBORDY, 
as President of the Board of 
Directors 

JOSEPH CALIFANO, as United States 

Secretary of Health, Education 
and Welfare, 

IAM T. PAYNTER, M.D., as 
ate Health Commissioner for the 

Indiana State Board of Health, 

JAMES WHITE, as Director of the 
Division of Hospital and 
Institutional Services of the 
Indiana State Board of Health, 

DAVID J. EDWARDS, M.D., as 

Director of the Health Facilities, 

Bureau of the Indiana State Board 
of Health, and 

KIPTON KAPLAN, as Executive 
Director of the Northern Indiana 
Comprehensive Health Systems 
Agency, Inc. 

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Defendants 

AFFIDAVIT OF SERVICE   

  On the &d \ . day of % LA so y 1977, Bruce E. Sayers, 

Attorney for defendants, Methodist Hospital of Gary, Inc. and 

Denis E. Ribordy, served a true and correct copy of defendants’ 

 



® ¢ 

  

Motion for Enlargement of Time in Which to Answer Interrogatories 

and proposed Order granting defendants' Motion for Enlargement of 

Time in Which to Answer Interrogatories on the following named 

individuals by depositing same in the United States Mail, first 

class, postage prepaid and addressed to the following named 

individuals as follows: 

Jack Greenberg 
Melvyn R. Leventhal 
Beth J. Lief 

10 Columbus Circle 
New York, New York 10019 

Julian B. Allen 

Charles B. Miller 
2009 Broadway 
Gary, Indiana 46407 

Marilyn G. Rose 
Christine G. Hickman 

1751 8. Street, N.W. 
Washington, D.C. 20036 

Fred Grady 

Assistant United States Attorney 
507 State Street 
Hammond, Indiana 

HODGES, DAVIS, GRUENBERG, COMPTON 
& SAYERS 
4 TT 

4 [ ™ ™ | EAA / 

By: IS Ta oh Aes   

Bruce E. Sayers 
5525 Broadway 

Gary, Indiana 46410 
Ph. (2135) 981-2557 

 



HoDGEs, Davis, GRUENBERG, COMPTON & SAYERS 

ATTORNEYS AT LAW 

5525 BROADWAY 

GARY, INDIANA 
46410 

Mr. Jack Greenberg 
Mr. Melnyn R, Leventhal 
Ms. Beth J. Lief 
10 Columbus Circle 
New York, New York 10019 [||4c5389db-e90c-41dc-af43-5d40a545c245||]